Shopping for Memory Care? A New Bill Forces Facilities to Put Their Hidden Rules on Paper.
Sponsors: Lisa Feret, Amy Paschal·Health & Human Services·

Illustration: Assembly Required
The Bottom Line
If you are looking for memory care for a loved one, this bill forces facilities to clearly disclose their security protocols, restraint guidelines, and hidden fees upfront. It also tackles healthcare staffing shortages by allowing nurse aides and practical nurses to administer injections without a registered nurse having to be in the building.
What This Bill Actually Does
House Bill 26-1107 tackles two massive pain points in Colorado's healthcare system: the lack of transparency in dementia care facilities and the ongoing bottleneck in medical staffing. The bill is divided into two distinct halves, both aimed at making regulated care facilities function better for the people relying on them.
The first half of the bill (Sections 1 and 4) creates strict new transparency rules for any licensed facility that advertises memory care or dementia services. Right now, families comparing memory care centers often have to rely on glossy brochures and sales pitches. HB26-1107 changes the game by requiring the Colorado Department of Public Health and Environment (CDPHE) to create a standardized Dementia Care Services Information Form by January 1, 2027. This form forces facilities to put their hardest policies in writing. They will have to disclose their specific guidelines for using physical and chemical restraints, their security features to prevent residents from wandering, the criteria they use to kick a resident out (discharge or transfer), and exactly how and when they notify families about injuries. They also must provide a link to federal databases showing their past fines and enforcement actions, along with a rock-solid fee schedule so families aren't caught off guard by hidden costs.
The second half of the bill (Sections 2, 5, and 6) addresses operational bottlenecks by expanding who can give a patient a shot. Under current law, administering medication by injection is highly restricted. This bill expands the legal definition of "administration" to include injections and allows Licensed Practical Nurses (LPNs) and Certified Nurse Aides (CNAs) to administer them, provided they complete a specific state-approved training program. Crucially, the bill outlaws facility policies that require a Registered Nurse (RN) to be physically on-site just to supervise an LPN or CNA giving an injection. It also expands the state's Qualified Medication Administration Personnel (QMAP) program—which currently operates in about 650 assisted living centers—to cover all 4,500 licensed health facilities in the state.
What It Means for You
If you have an aging parent or loved one showing signs of Alzheimer's or dementia, you already know that choosing a care facility is one of the most stressful, overwhelming decisions a family can make. You are often making the choice during a crisis, and it is incredibly difficult to compare one facility to another. HB26-1107 is designed to give you a clear, apples-to-apples comparison tool. Beginning July 1, 2027, any facility offering dementia care must hand you their completed disclosure form the moment you ask about services. They also have to post it publicly on their website.
This means you will not have to guess or aggressively interrogate a sales director to find out their policy on chemical restraints, or what happens if your parent's condition worsens and the facility decides they can no longer handle them. The required fee schedule disclosure is also a massive win for your wallet. It forces the facility to explain exactly what services are covered by their base rate, what costs extra, and the exact process for how they will notify you if they decide to hike those fees. If you are a healthcare worker—specifically an LPN or a CNA—this bill gives you a path to expand your skillset and value in the workplace by getting certified to administer injections, though you will see a microscopic fee increase (about $1 to $2) on your biannual license renewal to fund the program's oversight.
Here is what you should do to stay ahead of this:
- Have the conversation early: If you anticipate needing memory care for a relative in the next few years, start researching facilities now, but know that by summer 2027, you will have a standardized state form to demand from them.
- Healthcare workers, look for training: If you are an LPN or CNA, start asking your employer if they will cover the cost of your injection administration training once the new CDPHE rules are finalized. Getting this certification will make you highly competitive.
What It Means for Your Business
If you operate a memory care center, an assisted living facility, or a third-party healthcare training business, HB26-1107 is going to fundamentally change your operations and compliance checklist. For dementia care facilities, the transparency mandate is the heavy hitter. By July 1, 2027, you must publish the state's new disclosure form on your website and hand it to every prospective client. This means you have about a year to audit your internal policies regarding physical/chemical restraints, wandering security, and discharge criteria. If those policies are currently vague, you need to tighten them up before they become public-facing documents. The stakes here are high: failing to maintain and provide this updated form is officially classified as a deceptive trade practice under the Colorado Consumer Protection Act. That means a disgruntled family could report you, and you could face civil penalties of up to $20,000 per violation, per day.
On the staffing side, the news is overwhelmingly positive for facility operators. The chronic shortage of Registered Nurses has created massive bottlenecks in patient care, forcing facilities to pay premium rates just to have an RN on-site to handle simple injections. By allowing properly trained LPNs and CNAs to administer injections without an RN physically in the building, this bill gives you significant scheduling flexibility and potential payroll relief. Furthermore, if you run a business that provides QMAP training, prepare for a surge in demand. The state expects about 25,500 existing registrants to seek retraining to qualify for injection administration, and the QMAP program is expanding from 650 to 4,500 eligible facilities.
Here is what business owners should do THIS WEEK:
- Audit your dementia policies: Pull your current resident handbooks and internal protocols on restraints, wandering, and fee changes. Ask yourself: "Are we comfortable posting this exactly as written on our public website?" If not, start revising.
- Forecast your training budget: Identify which of your current LPNs and CNAs are the best candidates for the new injection training program. Earmark funds to get them certified as soon as the CDPHE approves the new curriculum.
- Trainers, prep your curriculum: If you are a third-party QMAP contractor, start drafting curriculum additions for injection administration so you are ready to submit for CDPHE approval the moment the rules drop.
Follow the Money
According to the fiscal note, this bill is essentially self-funded by the healthcare industry rather than general taxpayers. Implementing the new rules, facilitating stakeholder meetings, and handling the expected uptick in compliance complaints will cost the state $88,770 in FY 2026-27 and bump up to $317,347 in FY 2027-28 (primarily to hire staff to review all the new QMAP training programs).
To cover these costs, the state will rely on cash funds. Third-party trainers will pay fees to the Medication Administration Fund when they submit their new curriculums. Additionally, LPNs and CNAs will cover the enforcement costs through a tiny increase in their biannual license renewals—estimated at just $2 for LPNs and $1 for CNAs. There is also a "wildcard" revenue source: the Attorney General and local district attorneys can seek up to $20,000 in civil penalties against facilities that commit a deceptive trade practice by hiding or failing to update their dementia care forms. While the state hasn't projected exactly how much penalty money will come in, non-compliant facilities could end up footing a very painful bill.
Where This Bill Stands
HB26-1107 was introduced in the House on February 3, 2026, and immediately assigned to the House Health & Human Services Committee.
Because this legislation addresses two universally acknowledged problems—protecting vulnerable seniors from hidden facility practices and easing crippling healthcare staffing shortages—it has strong practical momentum. The fact that it doesn't require a massive carve-out from the General Fund also significantly boosts its chances of survival in a tight budget year. You can expect some lively debate in committee from facility operators who might push back on exactly how much detail goes into the dementia disclosure form, but the core provisions of the bill are highly likely to advance. Keep an eye out for the first committee hearing schedule, which is where industry lobbyists will attempt to soften the "deceptive trade practice" penalty.
The Opportunity Signal
Where this bill creates practical upside for operators: the opening, the key constraints, and the move to make while the window is still favorable.
Healthcare Workforce Training Expansion
The bill significantly expands the scope of practice for Licensed Practical Nurses (LPNs) and Certified Nurse Aides (CNAs) by allowing them to administer injections after completing a state-approved training program. This change addresses chronic staffing shortages in healthcare facilities by reducing reliance on Registered Nurses for routine injections and broadens the Qualified Medication Administration Personnel (QMAP) program to cover 4,500 licensed health facilities, up from 650. This creates a substantial demand for specialized training, offering a clear revenue growth opportunity for existing and new healthcare training providers, while also improving operational efficiency for facilities.
- Target audience: Approximately 25,500 existing LPNs and CNAs in Colorado will seek new injection administration certification.
- Program expansion: QMAP program eligibility grows from 650 to 4,500 facilities, creating new demand for certified personnel.
- Regulatory timeline: CDPHE will approve new curricula; training providers must submit for state approval as soon as rules drop.
Next move: Third-party QMAP contractors and other training businesses should immediately begin drafting curriculum additions for injection administration to be ready for CDPHE approval. Connect with the CDPHE division responsible for QMAP program oversight within the next 30 days to understand the anticipated submission and approval process.
Memory Care Policy & Compliance Consulting
Memory care facilities are now legally mandated to disclose detailed policies on restraints, wandering security, discharge criteria, injury notifications, and fee schedules via a standardized state form by July 1, 2027. This radical increase in transparency means facilities must audit and potentially revise their current internal policies to withstand public scrutiny. Failure to comply or provide accurate information is classified as a deceptive trade practice, exposing facilities to civil penalties of up to $20,000 per violation, creating a critical demand for specialized compliance and policy advisory services.
- Legal trigger: Mandatory disclosure form due to CDPHE by January 1, 2027, public posting and client distribution by July 1, 2027.
- High stakes: Non-compliance can result in $20,000 civil penalties per violation under Colorado Consumer Protection Act.
- Service scope: Consulting on policy auditing, drafting clear guidelines, and ensuring public-facing documentation meets new state standards.
Next move: Consulting firms specializing in healthcare regulation or legal services should prepare a 'Dementia Care Policy Audit' service offering. Reach out to local memory care facilities in the next 30 days to offer preliminary policy review consultations, highlighting the upcoming compliance deadline and penalty risks.
Digital Compliance Tools for Senior Care Facilities
The bill mandates that memory care facilities not only disclose a standardized 'Dementia Care Services Information Form' but also post it publicly on their website and provide links to federal databases detailing past fines. This requirement for dynamic, publicly accessible information creates a need for specialized software or web-based tools that can efficiently manage, update, and display complex compliance data. Entrepreneurs can develop platforms that simplify form generation, ensure website integration, and automatically link to relevant federal enforcement databases, saving facilities significant administrative burden and reducing compliance risk.
- Required elements: Standardized form, public website posting, links to federal enforcement and fine databases.
- User need: Facilities require tools for easy management, updating, and compliant display of sensitive policy and financial information.
- Market timing: Facilities need solutions well before the July 1, 2027, public disclosure deadline to avoid manual processes and legal risks.
Next move: Software developers and web service providers should research existing senior care facility website platforms and compliance tools to identify gaps. Prepare a proof-of-concept for a 'Dementia Disclosure Management System' or a website module, focusing on ease of use and automated linking features, to present to potential facility clients or associations within the next 60 days.
Get the Wednesday briefing
Colorado legislature coverage, in plain language. Free.
Frequently Asked Questions
What does HB26-1107 do?
What is the current status of HB26-1107?
Who sponsors HB26-1107?
How does HB26-1107 affect Colorado businesses?
What committee is reviewing HB26-1107?
When was HB26-1107 last updated?
Related Bills
Colorado is Cleaning Up Its Behavioral Health Rules (And What It Means for Local Pharmacies)
In Committee
HB26-1238Colorado is Finally Declaring Ambulances an "Essential Service" — Here's Why It Matters.
In Committee
HB26-1069The End of the Default ER Trip: How Colorado is Changing the Ambulance Business
In Committee
HB26-1044Measures to Improve Black Maternal Health Equity
Introduced